US tax advice around the world

If you are a US citizen living abroad, or have assets or operations in the US, you will be all too familiar with the challenges when exposed to more than one legal system and the need for specialist advice and advisors who understand both sides of the Atlantic.

You may be a US citizen living abroad who needs integrated estate planning or tax advice, or a non-US individual with US connections such as gifts to family members, real estate or owning a business. Or you may be a non-US company looking to form or manage a US business or non-US charity with US connections such as donors or investments. If you have come to a decision to give up your US citizenship and expatriate, we can guide you through this complicated process, working with our immigration lawyers in Europe, the US and Asia.

To assist with this, we have a dedicated team of US tax and private client lawyers in our London, Geneva, Hong Kong and Singapore offices to provide integrated advice under one roof. Our advice is based on real experience and how we endeavor to find practical and creative solutions for the complex multi-jurisdictional issues you face.

Our dedicated team in London is one of the largest of its kind outside of the US. The team also works collaboratively our colleagues throughout the world, as well as with outside advisors both in the UK and across the globe to achieve optimal solutions for clients.

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Non-dom update


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Recognition

Ranked in top tier for personal tax, trust and probate

Ranked in Band 1 for private client for the last 16 years

Leading firm for private wealth

UK top 25 private client law firm 2017

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We enjoy working with a dynamic US/UK legal team in London and now collaborate across a wide range of practices within the firm. Acting together, we are able to offer advice on virtually every aspect of a client’s tax and financial planning.

BUZZACOTT - CHARTERED ACCOUNTANTS
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Withers is the law firm we look to for legal issues for our US/UK clients; often with a complex tax background. The firm’s depth of knowledge and experience is excellent, on all trust and tax related legal issues, including tax controversy.

Julian Nelberg, Director - PwC

Transatlantic thinking - for families with US and UK connections


We work with couples with one foot either side of the pond, all the time. We have seen virtually every tax and financial situation that can affect couples who have to consider their obligations both to the UK Government and to Uncle Sam.

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Meet the team

How the team can help

Track record

European family with US connections

We advised our client, a non-domiciled UK resident and his family on a new structure that was required to be efficient from a US and UK perspective and with trusts designed to optimize tax efficiency for his children on the event of his death. Our family team also advised on a multi-jurisdictional post nuptial agreement.

US citizen buying UK property

Buying property in a different country can be more complicated between some jurisdictions and in particular for a US buyer in the UK. Our integrated US team in London working with our UK tax and property teams were able to assist our US client to buy the UK residential property, utilizing debt finance from his US trust structure. It was important to get the interplay between US and UK estate taxes right for him in light of him also becoming a UK tax resident, so we have advised on his broader estate planning too.

A high-profile family

A prominent non-US family contacted Withers for advice on creating tax efficient structures to help them invest in US property and business. Withers' years of invaluable experience in this area allowed us to help them to navigate their tax liabilities in the US and their country of domicile, avoiding a potential 'double tax' bill.

US / UK interests

We assisted a family in efficient structuring of the family's business activities in the US and the UK as well as their family charitable foundation. The unique nature of our US team based in London enabled us to provide both the UK and US advice on the structuring and charitable foundation under one roof.

A Jersey trust

Advised the trustee of a Jersey trust, working alongside US colleagues, on the conversion of that trust to a grantor trust for US tax purposes while walking the fine-line to preserve the favourable tax regime of the trust for UK tax purposes and avoiding triggering UK tax issues on the conversion.

US tax compliance for Brazilian entrepreneur

We investigated the circumstances of a client who was a Brazilian entrepreneur investing in the United States. We determined that he had inherited United States citizenship from his parents but had never filed US income tax returns or reporting forms. We quickly and efficiently addressed the noncompliance by entering him into the IRS offshore streamlined program.

Reorganization of estate

A reorganization of the estate of a US citizen with a valuable Cayman shareholding resulted in an immediate saving for his family of over £100m tax. Involving private client as well as the family teams in the US and UK.

Chilean US family tax work

Working with a Chilean–US family, we helped to address compliance deficiencies in their family wealth succession planning structure. Small modifications to the structure substantially decreased US annual taxation and simplified reporting, addressing the US family members' income tax, FBAR and FATCA reporting issues. We also liaised with Chilean banks to quickly unfreeze needed accounts.

The US-born son of a UK businessman

When he became engaged to a Swiss citizen, the son of a high-profile UK businessman asked us to help him obtain a British Passport and expatriate from the US. We were also asked to draft a prenuptial agreement. Timing was of the essence but as a global, full-service firm we created a team of immigration, family and private client lawyers to meet tight deadlines.

Brazilian family offshore structuring

We worked alongside Brazilian counsel to advise a client on the FATCA and CRS reporting requirements applicable to their complex succession structure for his offshore assets. These included a private trust company, trusts, companies and other entities, a private investment fund and multiple investment accounts, and involved the Bahamas, the Cayman Islands, Switzerland and the US. The advice also needed to take into account the client's plans to relocate his family from Brazil to London, and possibly thereafter to New York City.

Pre-immigration planning for Brazil-USA move

A Brazilian private equity fund executive requested advice on pre-immigration planning in connection with his relocation to the United States. We helped to coordinate the timing of his tax recognition from certain transactions to occur while he was still a Brazilian tax resident and others to be taxed after becoming a US tax resident. We also established different types of trust structures to protect assets from US estate tax, a foreign trust to defer income taxation on existing carried interests, and a traditional US estate planning trust for carried interests not yet paying out.

Chilean child US tax

A Chilean family's child was an accidental American by virtue of birth, and we helped them to address US tax reporting issues and eliminate future entanglement with the US.

Russian family relocating

Advised a Russian client on relocating him and his family to the UK in the context of the UK statutory residence test, including advising on managing the tax implications of his role in the business, purchase and use of residential and investment property in the UK and elsewhere (such as appropriate property holding structures) and detailed advice on how to maximize remittance planning techniques with respect to sources of funds generated prior to and after his arrival in the UK.

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